1. Elk River views transparency as a core component of efficient and ethical corporate governance and manages its business on a completely open and transparent basis, accepting full responsibility for all of its transactions.

2. Elk River is committed to the highest standards of service and works in full compliance with international laws and directives.

3. It is Elk River’s policy to provide a secure working environment for its staff by establishing and maintaining the necessary security measures to prevent unlawful acts which may endanger the security of persons and property.

4. Elk River guarantees its commitment on matters of law and security and declares that all work conducted by its personnel will be effectively supervised in order to comply with international counter-terrorism provisions.

5. Elk River recognizes the positive impact that sound financial and security management practices have in reducing the threats of terrorism and other criminal activity and hereby commits to:

Observing national and international laws and regulations regarding criminal risks

Continuing and maintaining the practice of good management

Safeguarding and protecting its employees, visitors and its own assets

Conducting a periodic risk assessment with regard to its commercial activities and transactions

6. Elk River’s due diligence includes a comprehensive process of information gathering concerning its clients – “know your client” – and the services provided; a criticality assessment that identifies the company’s critical assets and processes; a threat assessment that evaluates relevant threats; and a vulnerability assessment that pinpoints areas of possible weakness.

7. Elk River agrees to appoint and empower a qualified employee to have overall responsibility for verifying compliance with regulations and will provide the necessary support to that person to enable him/her to fulfil these duties and responsibilities.

8. Elk River commits itself to cooperate fully with relevant national and international authorities and to act upon their advice.

9. Elk River is committed to promoting security awareness amongst all employees through comprehensive training.

10. Elk River ensures a reporting and recording system for incidents of security breach and forwards the information collected to the relevant authorities.

11. Should there be any conflict between the commercial interests of the company and the aims of this security policy, Elk River’s management will always give priority to the rules set out in this policy document.